Epstein Secrets

extravagant New York lifestyle, including a "massive" Upper East Side apartment, he failed to fulfill his alleged promise to "have her admitted" to the Fashion Institute of Technology ("FIT"). More than ten years later, based on these events, Jane Doe filed the original Complaint (and now the FAC) in which, astonishingly, she cla

Court Should Modify the Protective Order I I CONCLUSION 15 CONFIDENTIAL - FILED UNDER SEAL EFTA00805390 TABLE OF AUTHORITIES Page(s) Cases Abarca v. Little, 54 F. Supp. 3d 1064 (D. Minn. 2014) 4 Charter Oak Fire Ins. Co. v. Electrolux Home Prods., Inc., 287 F.R.D. 130 (E.D.N.Y. 2012) 11, 1

ns of fraud boil down to this: Epstein allegedly "confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff admitted into the Fashion Institute of Technology" ("E") and to advanced her career, but had no intention of doing so. FAC ¶¶ 38, 53, 58-64. This is insufficient to satisfy Rule 9(b). First, the F

menced until January 27, 2017, more than four years after any of the events alleged in the FAC occurred. Plaintiff's claim is therefore time-barred. Abarca v. Little, 54 F.Supp.3d 1064, 1068 (Minn. 2014). As the Court stated in Abarca, a claim under Section 1595 had a four-year of statute of limitation

again that her sexual compliance would be SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00285645 16 I877DOEC rewarded with admission to the Fashion Institute of Technology or a comparable college, a promise which they knew to be false." 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

that analysis has been applied to conclude that the ten year statute of limitations applies. We cited a case out of the District of Minnesota, the Abarca case, that takes a different view, and the thinking in the Abarca case -- which we think is the correct thinking -- THE COURT: So far the thinking

ns of fraud boil down to this: Epstein allegedly "confirmed to Plaintiff that he would use his wealth and influence to have Plaintiff admitted into the Fashion Institute of Technology" ("E"), but had no intention of doing so. Cplt. ¶¶ 37, 50, 53-55. This is insufficient to satisfy Rule 9(b). First, the Complaint fails to identify

until January 27, 2017, more than four years after any of the events alleged in the Complaint occurred. Plaintiff's claim is therefore time-barred. Abarca v. Little, 54 F.Supp.3d 1064, 1068 (Minn. 2014). As the Court stated in Abarca, a claim under Section 1595 had a four-year of statute of limitation